device test (Missouri) · Go Syfert
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device test in Missouri

10 Missouri opinions name it 2 courts 1998–2024 1 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
In Re Estate of Goldenberggreen
moctapp · 1980 · cited in 8 Missouri opinions naming this issue, 1998–2024
2 sentences

2024However, “[t]he statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes [among] heirs.” Ryan v. Spiegelhalter, 64 S.W.3d 302, 305 (Mo. banc 2002) (quoting In re Goldberg’s Est., 601 S.W.2d 637, 639 (Mo. App. E.D. 1980).

2008Civil Rules of Practice sec. 52.01-2); see Kemp v. Balboa, 959 S.W.2d 116, 118 (Mo.App.1997). 8 ."In a discovery of assets proceeding, the court’s role is to determine whether specific property has been adversely withheld or claimed.” Ryan v. Spiegelhalter, 64 S.W.3d 302, 305 (Mo. banc 2002). " 'The statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes among heirs.' ” Id. (quoting In re Goldenberg's Estate, 601 S.W.2d 637, 639 (Mo.App.1980)). '“A discovery of assets action, as its name implies, is a search for assets.’

68
Beverly Sue Ryan, P.A. v. Spiegelhaltergreen
mo · 2002 · cited in 4 Missouri opinions naming this issue, 2002–2024
2 sentences

2024However, “[t]he statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes [among] heirs.” Ryan v. Spiegelhalter, 64 S.W.3d 302, 305 (Mo. banc 2002) (quoting In re Goldberg’s Est., 601 S.W.2d 637, 639 (Mo. App. E.D. 1980).

2008Civil Rules of Practice sec. 52.01-2); see Kemp v. Balboa, 959 S.W.2d 116, 118 (Mo.App.1997). 8 ."In a discovery of assets proceeding, the court’s role is to determine whether specific property has been adversely withheld or claimed.” Ryan v. Spiegelhalter, 64 S.W.3d 302, 305 (Mo. banc 2002). " 'The statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes among heirs.' ” Id. (quoting In re Goldenberg's Estate, 601 S.W.2d 637, 639 (Mo.App.1980)). '“A discovery of assets action, as its name implies, is a search for assets.’

44
STATE, EX REL. KNIGHT v. Harmangreen
moctapp · 1998 · cited in 2 Missouri opinions naming this issue, 2002–2008
2 sentences

2008Knight v. Harman, 961 S.W.2d 951, 954 (Mo.App.1998)). 9 .

2002Knight v. Harman, 961 S.W.2d 951, 954 (Mo.App.1998)).

22
Matter of Estate of Woodrumgreen
moctapp · 1993 · cited in 2 Missouri opinions naming this issue, 1998–2000
2 sentences

2000E.D.1980), nor does it provide a forum for the probate court “to try an action for breach of contract.” Estate of Woodrum, 859 S.W.2d 259, 262 (Mo.App.

1998Also, in In the Matter of the Estate of Woodrum, the court found that a claim to recover on a surety bond covering a discharged conservator was an action for breach of contract and, as such, the probate division of the circuit court “does not have the authority to try an action for breach of contract.” 859 S.W.2d 259 , 262 (Mo.App.1993). 5 The petition for discovery of assets does not allege, with regard to Abele, that he “claims an interest in property which is claimed to be an asset of the estate,” nor does it request the “determination of the title, or right to possession thereof’ of proper

12
Kemp v. Balboagreen
moctapp · 1998 · cited in 1 Missouri opinions naming this issue, 2008–2008
1 sentence

2008Civil Rules of Practice sec. 52.01-2); see Kemp v. Balboa, 959 S.W.2d 116, 118 (Mo.App.1997). 8 ."In a discovery of assets proceeding, the court’s role is to determine whether specific property has been adversely withheld or claimed.” Ryan v. Spiegelhalter, 64 S.W.3d 302, 305 (Mo. banc 2002). " 'The statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes among heirs.' ” Id. (quoting In re Goldenberg's Estate, 601 S.W.2d 637, 639 (Mo.App.1980)). '“A discovery of assets action, as its name implies, is a search for assets.’

11
Estate of Williams v. Williamsgreen
mo · 2000 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002“In a discovery of assets proceeding, the court’s role is to determine whether specific property has been adversely withheld or claimed.” Ryan, 64 S.W.3d at 305 ; see Estate of Williams, 12 S.W.3d at 305 . “ ‘The statute is not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes among heirs.’ ” Ryan, 64 S.W.3d at 305 (quoting Estate of Goldenberg, 601 S.W.2d 637, 639 (Mo.App.1980)). “ ‘A discovery of assets action, as its name implies, is a search for assets.’ ” Id. (quoting State ex rel.

11
United States v. Turkgreen
ca5 · 1976 · cited in 1 Missouri opinions naming this issue, 1998–1998
1 sentence

1998United States v. Turk, 526 F.2d 654, 658 (5th Cir.1976).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Ryan Ex Rel. Estate of Reece v. Reece green
moctapp · 2000
1 sentence

2001A petition for discovery of assets is “not intended as a device to test general fiduciary conduct, improper administration of the estate, or general disputes between hems.” Reece, 31 S.W.3d at 87 (quoting In re Goldenberg’s Estate, 601 S.W.2d 637, 639 (Mo.App.

12001–2001

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 473.340 (9) MO § Mo. Rev. Stat. § 472.010 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MO 10 (1998–2024) CA 7 (1942–2025) NC 6 (2001–2026) NY 4 (1962–1983) NJ 3 (2008–2023) TX 2 (1991–2016) MN 2 (2015–2015) SC 2 (1956–1956)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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